Additionally, the risk assessment must focus on capacities and capabilities. Instead of just identifying threats, the assessment needs to address a SNF’s ability to remain operational during an emergency or disaster to help ensure the continuation of services. While there are many tools available to address potential hazards like fire, flood, power failure, tsunami, violence, civil disturbance and a long list of perils illustrated within a HVA tool, the process to assess capacities and capabilities is not quite as standardized.
Providers will need to analyze their resident populations, staffing capacities and other operational capabilities to determine specific needs and vulnerabilities as well as their capacity to provide services during an emergency in accordance with their own unique circumstances. Consequently, a facility will need to take a customized approach to assess capacities and capabilities and incorporate this information in the emergency plan, since a standardized tool to perform this element of assessment is not readily available.
Once the assessment process is done, providers can develop their emergency plan based on all the information on threats and the capacity to handle them. The utilization of an all-hazards approach in an Emergency Plan means some type of standardized method of managing these critical events must be utilized.
During my days in the fire service, an all-hazards approach began to evolve back in the 1980s when fire departments around the nation started to incorporate the Incident Command System (ICS) into their operations. Having a standardized management model like the ICS integrated into an emergency plan will help a provider manage any emergency, regardless of the root cause of the event through an all-hazards approach. To help long-term care providers embrace and utilize ICS in their specific environment of care, a derivative of ICS known as the Nursing Home Incident Command System or NHICS is also available online.
It clearly makes sense for emergency plans to be developed using an all-hazards approach. However, in my experience as a consultant and prior to the publication and enforcement of the new CMS regulations, I can tell you that risk assessment has not been a routine part of the long-term care community emergency plans I have reviewed in the past.
Policies and Procedures
CMS will require that policies and procedures be created and implemented based on the findings of the risk assessment and the development of emergency plan. These policies and procedures must be reviewed at least annually and updated as needed. The information contained in the policies and procedures must be very specific and must address the provisions of subsistence needs such as food, water and medical supplies for staff and residents who shelter in place during in emergency situations.
Other highlighted area of policies and procedures development includes the following: